IN THE STATE COURT OF BROOKS COUNTY

STATE OF GEORGIA

STATE OF GEORGIA
Plaintiff

v.

RICHARD JERRY McLEOD

Defendant

MOTION TO PRESERVE AND PRODUCE EVIDENCE

Pursuant to Georgia code 24-10-26 and the Due Process Clauses of the United States and

Georgia Constitutions, Defendant hereby moves for an order requiring the prosecution to

preserve and provide defendant with access to any and all items of evidence including but not

limited to the following items:

a. All video or audio recordings including but not limited to E911 and sheriff radio
transmissions.

b. All law enforcement police notes, Defendant is aware that it is the practice of law
enforcement to destroy their notes, Defendant specifically requests an order specifically ordering
law enforcement agencies to preserver all note inn this case.

c, All photographic evidence made in this case (specifically including but not limited to all the
individual photographs taken at all times of defendant seized dogs - and that such
photographs be produced in a format of easily readable form without further transcription or
computer conversion. These photographs to be unaltered from originals.

d. Unaltered copies of all necropsies performed of any of defendants dogs.

e. Unaltered copies of any veterinary diagnostic reports on defendants dogs in plain readable
text without need for any file conversion.

f . Copies of all reports specifically detailing disposition of defendants seized dogs; showing

Names of persons receiving the dogs and the address and locations of these recipients.

g.. Names, location of any so called rescue or adoption agencies receiving any of the
aforementioned seized dogs.

h. Copies of all euthanization reports from all entities receiving the seized dogs.

I. Copies of a complete current inventory of any and all of defendant seized dogs presently
impounded or in custody o Thomasville Thomas County Humane Society, Nates Patch or any
other affiliated entity receiving the subject dog.

j. Copies of all invoices, adoption receipts and all other documents showing the amounts received
by all persons in exchange for defendants dogs.

k. All correspondence including email, text messages, written correspondence or any other
communications between law enforcement internally or with any of the agencies or other
affiliates involved in the investigation of this case.

j. Defendant requests copies of all supporting statements made to Magistrate and all sworn
statements so given in support of affidavit for search warrant - And a copy of this affidavit.

Respectfully,

Jerry McLeod Pro Se

1675 Liberty Church road
\Boston, Georgia 31626
229-263-7981
December 8, 2016

CERTIFICATION
I HEREBY CERTIFY that I have this day served plaintiff with a copy of foregoing motion to
produce evidence by faxing an exact copy and mailing a copy to the person at address listed
below :

Robert Gilchrist
Office of the District Attorney
Post Office Box 99
\Valdosta, Georgia 31603